Manor Care, Inc. v. United States, 630 F.3d 1377 (Fed. Cir. 2011), aff'g, 89 Fed. Cl. 618 (2009)

(plaintiff, nursing home operator, denied WOTC for about 3,000 employees and defendant's delay in clarifying eligibility requirements for WOTC did not entitle taxpayer to refund; certification errors by state offices could not be corrected in federal tax proceedings).